The CSDDD (Corporate Sustainability Due Diligence Directive), approved on 24 May 2024, requires companies to assess and report their negative impacts on human rights and the environment. The EU has simplified its implementation through the Omnibus package, which modifies key aspects of the directive.
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[Last updated: 21 November 2025, based on the communication from the European Parliament.]
General context following the simplification amendments (Omnibus I 2025)
The CSDDD was adopted in 2024, but the Commission (February 2025), the Council (June 2025) and now Parliament (November 2025) have driven substantial changes to reduce obligations, limit the scope and simplify processes.
Negotiations between Parliament and Council are currently ongoing (trilogues since 18 November 2025) with the aim of finalising the text by the end of 2025.
Due diligence is a process that enables companies to identify, prevent, mitigate and take responsibility for how they address their actual and potential adverse impacts. In this article, we summarise the key aspects of the European directive on corporate sustainability due diligence (CSDDD).
The CSDDD or CS3D (Corporate Sustainability Due Diligence Directive or Corporate Sustainability Due Diligence Regulation) is based on:
Several EU Member States (including France, the Netherlands and the United Kingdom) already have national due diligence rules in the ESG (Environmental, Social and Governance) field. The EU-wide directive aims to harmonise implementation and civil liability frameworks, as well as to broaden efforts across the entire bloc.
This Directive, adopted by the Council of the EU in May 2024 after a lengthy legislative process, seeks to impose due diligence with regard to potential or actual adverse impacts on:
arising from companies’ own activities, those of their subsidiaries and those of their direct business partners.
Important change following the Omnibus package amendments:
They are required to comply with due diligence:
Following the Omnibus package amendments and Parliament’s position:
(Beforehand, the directive adopted in 2024 covered many more companies. The scope is now drastically reduced.)
The directive will also apply to non-EU companies that reach the same turnover thresholds within the European market.
The previous reference to fines of up to 5% of global turnover is removed.
Liability and sanctions will be exclusively national, not harmonised at EU level, and the Commission will only provide guidance.
(This is a convergence between the positions of the Council and Parliament.)
Non-EU companies will also be subject to the directive if they operate in the EU.
Third-country companies falling within the scope must appoint an authorised representative within the EU.
Even if a company falls outside the scope of the EU CSDDD, the increasing pressure to align operations and supply chains with ESG objectives is likely to drive similar legislation in other jurisdictions.
The Directive does not propose rules directly applicable to small and medium-sized enterprises.
In addition, following the simplification amendments, their protection is strengthened:
Companies must identify, prevent and mitigate negative environmental impacts, which includes waste management, with particular attention to hazardous waste.
Although the Omnibus package has relaxed responsibility in relation to indirect business partners, companies are still required to monitor the environmental impact of their direct suppliers, which may include their waste management practices.
Member States must:
Companies must:
For in-scope companies, the Directive will provide:
Despite the reduction in its scope and ambition, the Directive is still expected to help “level the playing field” for companies based or operating in the EU by creating a harmonised due diligence framework.
The European Parliament approved the Directive on 24 April 2024 and the Council of the EU gave its final approval on 24 May 2024. The Directive entered into force on 25 July 2024. Subsequently, the EU Omnibus package of February 2025 introduced significant amendments to the Directive.
Following the Omnibus package (stop-the-clock):
In 2028:
In 2029:
(Subject to revision following the simplification; this phase could be modified or removed depending on the final negotiations.)
In 2030:
IMPORTANT:
Parliament’s position limits the scope to only the very largest corporations, which could remove the 2029 and 2030 thresholds if it prevails in the final agreement.
These measures are under negotiation.
10. How is it related to the CSRD?
The CSRD provides the framework for companies to report on their sustainability performance and strategies, while the CSDDD complements this approach by requiring companies to act proactively in managing the risks and adverse impacts associated with their operations.
In addition, some aspects of the CSDDD, such as the adoption of transition plans for climate mitigation, are being aligned with the guidelines laid down in the CSRD, which contributes to greater coherence and simplification in meeting sustainability obligations.
At TEIMAS, we are committed to supporting businesses in navigating their new responsibilities in response to the EU’s "regulatory tsunami."
For this reason, we have prepared a series of workshops focused on explaining the most relevant regulations on sustainability and the circular economy.
Discover all the videos in the Surfing the Tsunami of Sustainability Compliance series here.
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